Interim Recommendation issued to: Civil Aviation Safety Authority

Between October 1995 and July 1997, the Bureau of Air Safety
Investigation undertook a study of the safety of Australian
regional airlines. The objectives of this study were to:

(a) identify safety deficiencies affecting regional airline
operations in Australia; and
(b) identify means of reducing the impact on safety of these
deficiencies.

For the purpose of the survey, regional airlines were grouped
according to the number of passenger seats fitted to the largest
aircraft operated by that airline in January 1997. The groups are
defined as follows:

(a) Group 1: 1-9 seats;
(b) Group 2: 10-19 seats; and
(c) Group 3: more than 20 seats.

The study involved analysing data obtained from:

(a) responses to a survey of Australian regional airline
employees;
(b) discussions with Australian regional airline employees and
managers;
(c) air safety occurrence reports involving regional airlines over
a 10-year period (1986-1995) from the BASI database.

This recommendation addresses one of the safety deficiencies
identified as a result of this study.

SAFETY DEFICIENCY

Training requirements for the initial issue of co-pilot instrument
ratings are inadequate and currency requirements for co-pilot
instrument ratings are not clearly defined.

FACTUAL INFORMATION

Survey results

Sixty-seven pilots (17%) reported that they held a co-pilot
instrument rating, rather than a command instrument rating, on
multi-engine aircraft. Seventy-four per cent of the pilots holding
a co-pilot instrument rating only were flying Group 3 aircraft
while 26% flew Group 2 aircraft. Aircraft from both Group 2 and
Group 3 were, in general, high-performance, complex aircraft.

Regulations

Pilots may obtain and exercise the privileges of a co-pilot
instrument rating. Candidates for co-pilot instrument ratings need
only satisfy the aeronautical experience requirements of the pilot
licence held. A co-pilot employed by a regional airline operator
would, as a minimum, require only the aeronautical experience of a
commercial pilot licence. Co-pilot candidates would then be
required to pass the Civil Aviation Safety Authority (CASA)
instrument rating exam in addition to an instrument rating flight
test. The instrument rating flight test must cover the same test
components as that of a command instrument rating test except that
the requirement to demonstrate proficiency in asymmetric flight is
limited to performance in the cruise phase of flight.

Note: It is also possible for a pilot who holds a command grade of
instrument rating for single-engine aircraft only, to act as a
co-pilot while the aircraft is flying in instrument flight
conditions.

Civil Aviation Order (CAO) 40.2.1 contains detailed recent
experience requirements that must be complied with in order to
exercise the privileges of an instrument rating. However,
references are only made to the pilot in command. Discussions with
CASA personnel indicated that while co-pilot recency requirements
were not specifically mentioned in CAO 40.2.1, the intention was
that co-pilot requirements are equivalent to pilot in command
requirements and are therefore implied within the CAO.
Notwithstanding, CASA staff agreed that this aspect of CAO 40.2.1
was ambiguous.

Current Australian regulations allow for co-pilot endorsements on
multi-engine aircraft that require multi-crew operations. The
syllabus of training for co-pilot aircraft endorsements, as
outlined in appendix V of CAO 40.1.0, does not require an element
of instrument flying. Civil Aviation Advisory Publication (CAAP)
5.23-1 (0), issued in September 1996, provides supplemental
guidance to the CAOs on the conduct of training for the initial
issue of a multi-engine endorsement (rating). The CAAP includes a
1-hour flight training exercise on instrument flying (where the
candidate holds an instrument rating) as part of the 8-hour flight
training section of the syllabus. As this information provides
advice only as to the preferred method for complying with Civil
Aviation Regulations, instrument flight training is therefore not a
mandatory element for the issue of a co-pilot endorsement.

Current multi-crew practices

Historically, co-pilots did not participate in flight deck duties
in the same way as the pilot in command. Co-pilots were employed
principally in a support or ancillary role with the majority of
flying duties, particularly critical phases of flight such as
takeoff, landing and instrument approaches, being undertaken by the
pilot in command. The current practice has changed considerably and
co-pilots are now expected to fly "leg-for-leg" during any one
period of flying duty. Whilst the pilot in command has ultimate
responsibility for the safety of the flight, the co-pilot
participates fully as the "flying pilot" in all phases of flight
including takeoff, landing and instrument approaches. Partly in
recognition of these increased responsibilities, many operators now
require applicants for co-pilot positions to hold a command
instrument rating and be eligible, pending accumulation of relevant
aeronautical experience, for an airline transport pilot licence.
Many co-pilots are now also expected to demonstrate proficiency in
all the elements of instrument flight including asymmetric
operations during critical phases of flight.

Proposed changes to co-pilot training requirements

Discussions with CASA personnel revealed that some consideration
is being given to the removal of co-pilot endorsements, and
therefore co-pilot instrument ratings, from current domestic
regulations. The Bureau was advised that one of the reasons for
this proposed change was so that domestic practice reflected
overseas practice. Co-pilot endorsements and co-pilot instrument
ratings are not available in many other countries.

ANALYSIS

Although there is no evidence to suggest that incidents or
accidents have resulted from this situation, the current limited
training requirements and the lack of definition of currency
requirements for co-pilot instrument ratings, have the potential to
impact on safety.

The current aeronautical experience requirements for co-pilots may
mean that some co-pilots would have limited background experience
to draw upon, particularly in asymmetric operations, and would
therefore be exposed to a greater risk of making skill- and
knowledge based-errors. As co-pilots are not expected to
demonstrate proficiency in asymmetric flight during an instrument
rating test in anything other than the cruise, and are not required
to undertake specific instrument flying exercises during co-pilot
aircraft endorsements, it is possible that deficiencies in
co-pilots' instrument flying skills during critical flight phases
such as takeoff, landing and instrument approaches, may remain
undetected. These potential deficiencies in experience and
proficiency may not be subsequently addressed in those cases where
an operator or individual has interpreted the CAOs such that they
do not consider that co-pilots need to meet the recency
requirements of the instrument rating. With little initial training
and limited ongoing practice, co-pilots' instrument rating skill
levels are not likely to be consolidated. Additionally, it is
possible that some co-pilots' experience in instrument flight
conditions, including instrument approaches, is likely to be gained
only on fare-paying, passenger-carrying flights and when the
co-pilot is not legally "current" in accordance with the intention
of CAO 40.2.1.

Given the current practice in both Australian and international
airlines regarding the participation of co-pilots in "leg-for-leg"
flying, it would seem more appropriate from a safety perspective
for co-pilots to be required to undertake the same instrument
rating training as that specified for a pilot in command.

Output text

The Bureau of Air Safety Investigation recommends that the Civil
Aviation Safety Authority give consideration to the removal or
amendment of the current co-pilot instrument rating requirements.
Notwithstanding, whilst the current regulations are in force, the
ambiguity in relation to recency requirements for co-pilot
instrument ratings should be addressed.

Initial response

Initial response

Date issued:

26 February 1999

Response from:

Civil Aviation Safety Authority

Action status:

Closed - Accepted

Response text:

I am writing in response to your letter addressed to [name
supplied] in which you requested advice on the Authority's proposed
action with respect to Air Safety Interim recommendation IR980176.
Please accept my apologies for this belated reply.

While it is noted that there is no direct evidence of safety
deficiencies resulting from the training specified in Civil
Aviation Orders for the holders of a co-pilot's Instrument Rating,
the Authority acknowledges the changed role of co-pilots in the
years since these regulations were first conceived.

In view of these changed circumstances, a review of the
applicability of the co-pilot Instrument Rating in the current
environment will be undertaken as part of the total review of the
flight crew licensing structure. This review will be the pre-cursor
to detailed work on the new Part 61 of Civil Aviation Safety
Regulations. The same review will also look at the applicability of
the co-pilot aircraft endorsement.

The licensing review has a high priority but, as you will
appreciate, it is a large undertaking involving many other complex
issues. Because no direct safety deficiency has been identified,
the review of the co-pilot requirement will proceed in the context
of the overall review. It is intended that a decision on the
licensing structure, including the need for specific co-pilot
qualifications will be made in the coming year.

With regard to the stated ambiguity of current recency
requirements, CASA does not agree that any ambiguity exists. CAO
40.2.1 clearly states that recency requirements only apply to the
pilot in command. The Authority's flight crew licensing section is
not aware that any other requirement was ever intended. Overseas
practice does not require recency for co-pilots in instrument
procedures as part of the licensing requirements, even where these
pilots are required to hold the equivalent of a commend instrument
rating.

It would be difficult to justify a unique licensing requirement
for formalised recency for co-pilots because an instrument approach
procedure flown by a co-pilot will always be monitored by a pilot
in command who is recent. Also, under the regulations which apply
to operators, co-pilots are required to undertake flight
proficiency and rating renewal tests at regular intervals which,
combined with the common practice of leg for leg flying by
co-pilots, ought to be adequate to maintain proficiency. Again, I
note that no specific safety deficiency has been identified in this
regard.

It may be that co-pilots' proficiency in asymmetric flight is a
matter which requires consideration and this will be taken into
account in the review of the co-pilot qualification.